Pinnacle Policy & Procedures
Data Protection Policy
Context and overview
Pinnacle Performance Company (Academy) [Pinnacle] needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the organization has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards and to comply with the law.
Why this policy exists
This data protection policy ensures Pinnacle:
Data Protection Law
The Data Protection Act 1998 describes how organisations, including Pinnacle, must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The Data Protection Act is underpinned by these important principles. These say that personal data must:
This policy applies to:
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
Data protection risks
This policy helps to protect Pinnacle from some very real data security risks, including:
Breaches of confidentiality. For instance, information being given out inappropriately.
Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with Pinnacle has some responsibility for ensuring data is collected, stored and handled appropriately. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
However, these people have key areas of responsibility:
The Exec VP of Marketing and Operations, Gerri Leon, is responsible for:
General staff guidelines:
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the operations manager.
When data is stored on paper, it should be kept in a secure place where unauthorized people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
When data is stored electronically, it must be protected from unauthorized access, accidental deletion and malicious hacking attempts:
Personal data is of no value to Pinnacle unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
The law requires Pinnacle to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort Pinnacle should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
Subject access requests
All individuals who are the subject of personal data held by Pinnacle are entitled to:
If an individual contacts the company requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email, addressed to the data controller at firstname.lastname@example.org.
The data controller will always verify the identity of anyone making a subject access request before handing over any information
Disclosing data for other reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Pinnacle will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Pinnacle aims to ensure that individuals are aware that their data is being processed, and that they understand:
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.